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Web-Distributed Labeling for Pesticide Products

Pesticide Registration Notice

Notice To: Manufacturers, Producers, Formulators, and Registrants of Pesticide Products

Attention: Persons Responsible for Initial and Continuing Federal Registration of Pesticide 

Products

Subject: Web-Distributed Labeling for Pesticide Products

This is a draft notice seeking public comment. EPA will consider the public comments received 

and may revise this notice before publishing a final version of this guidance.

This Notice presents the Agency’s guidance on optional participation in web-distributed labeling 

for pesticide products. The Agency believes that voluntary adoption of these recommendations 

by pesticide registrants will help pesticide users to better understand and comply with pesticide 

labeling. In addition, the Agency believes that web-distributed labeling could allow addition of 

new uses, modification of existing labeling requirements, and implementation of labeling-based 

risk mitigation measures more quickly. Registrants who wish to use these statements should 

follow the instructions in this notice. EPA undertakes initiatives such as this in order to make 

access to specific pesticide product labeling clearer and more user-friendly. The specific labeling

statements recommended in this Notice are intended to improve existing labeling by allowing 

users to download the portions of the pesticide labeling specific to their intended state and site of 

use. No registrant is required to take any action in response to this notice.

I. Products Potentially Affected by This Notice

This Notice is targeted to pesticide products marketed primarily to applicators for use in the 

course of commercial activity, such as commercial applicators applying to agricultural, turf, 

structural sites, and private applicators in the course of producing an agricultural commodity. If 

you have questions on whether or not this Notice applies to your product, please contact the EPA 

Product Manager or Regulatory Action Leader.

II. Scope of Policy 

This PR Notice provides guidance to pesticide registrants and to EPA. Although EPA encourages 

registrants to adopt the following options for making labeling content available via the internet, 

this notice is not binding on either EPA or pesticide registrants, and EPA may depart from this 

guidance in individual circumstances. Likewise, pesticide registrants who voluntarily choose to 

participate in this initiative may assert that the guidance is not appropriate for a specific pesticide 

or situation.

III. Background

Since 2007, the U.S. Environmental Protection Agency (EPA or the Agency) has been exploring 

the feasibility and advisability of allowing registrants to make legally enforceable pesticide 

product labeling available to users via the internet, an initiative referred to as “web-distributed 

labeling” (WDL). At the end of 2010, EPA initiated a “user acceptance pilot” that ran until 

April 2011. (75 FR 51058, August 18, 2010; EPA-HQ-OPP-2010-0632) The user acceptance 
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pilot involved a simulation of a WDL website that users could visit and on which they could 

provide feedback. The user acceptance pilot did not involve any changes to existing pesticide 

labeling on containers or legally valid electronic versions of pesticide labeling. EPA also 

published a Federal Register notice that outlined EPA’s positions on issues related to WDL and 

also sought comment on a number of these issues. (75 FR 82011, December 29, 2010; EPA-HQOPP-2010-0648)

Based on its review of the comments and other feedback received from the Federal Register

notice and the user acceptance pilot, EPA is proposing a voluntary approach to WDL that would

allow registrants to distribute pesticide products with labeling that refers the user to the website 

from which the user may download legally valid, enforceable labeling. The container would still 

be accompanied by a physical copy of the EPA-accepted labeling sufficient for the correct use of 

the product, but a user could access the most current version of the state- and site-specific

labeling from a website identified on the container label. Offering WDL while retaining the full 

labeling on or accompanying pesticide containers would allow users, registrants, and EPA to 

acquire a better understanding of the strengths and limitations of WDL and possibly serve as a 

transition to a system that relies more heavily on the internet and other technologies to provide 

users with legally enforceable labeling. For example, registrants could determine whether 

specific types of products would be better suited to WDL and users could evaluate the relative 

benefit of WDL versus the current pesticide product labeling.

As considered by EPA, WDL would make available via the internet site- and state-specific use 

directions for pesticide products as downloadable electronic files. To access this labeling, a user 

would visit the website identified on the pesticide label, enter information identifying the 

product, and select the intended state and use site. The website would return a streamlined 

version of the pesticide labeling containing the language applicable to all products, such as 

hazard and first aid statements, and the relevant state/site specific directions for use (e.g., 

application to cranberries in Maine). Sufficient labeling for the correct use of the product, i.e., 

the labeling currently included on or with the container, would still be available with the 

pesticide either on the container label or in accompanying material.

This PR Notice provides guidance about how EPA intends to implement WDL under this 

system. 

IV. Discussion of Issues and Recommendations

A. Terminology in this Notice

The list of terms below provides a description of the meaning of each term for the purposes of 

this notice only. These definitions do not supersede or otherwise alter any definitions contained 

in FIFRA or EPA’s pesticide regulations.

1. Master labeling – The complete set of EPA-accepted labeling information, including all 

approved uses and associated use information for a pesticide product registration, regardless of 

whether the complete presentation is actually distributed or sold with the product.
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2. Released for shipment – A product becomes released for shipment when the producer has 

packaged and labeled it in the manner in which it will be distributed or sold, or has stored it in an 

area where finished products are ordinarily held for shipment. Products stored in an area where 

finished products are ordinarily held for shipment, but which are not intended to be released for 

shipment must be physically separated and marked as not yet released for shipment. Once a 

product becomes released for shipment, the product remains in the condition of being released 

for shipment unless subsequent activities, such as relabeling or repackaging, constitute 

production. (40 CFR 152.3) 

3. Rendered output – The final version of WDL returned to a user for a product where the user 

has performed a search for labeling using the product’s unique identifier, a state and specific site. 

4. Unique identifier – For the purposes of this PR Notice only, an alpha-numeric combination 

used to distinguish the labeling for a specific version of the product from other products with the 

same registration number and different labeling as permitted under 40 CFR 152.130(b). The 

registrant would need to establish a new unique identifier if a change in the labeling would 

render the previously approved version of the labeling invalid, for example, in the event of a 

change to the precautionary statements, use classification, or packaging of the product. For 

example, if product A’s labeling version 1 advised users that the product was flammable, and the 

registrant reformulated product A to eliminate flammability, product A’s labeling version 2 

would need a different unique identifier than product A’s labeling version 1. The unique 

identifier must start with the EPA registration number and must be distinguished from the EPA 

registration number, establishment number, and distributor number. Registrants would develop 

the unique identifiers for each product to which WDL would apply. The unique identifier should 

be identified clearly as the unique identifier.

B. Description of Process for Adding WDL to a Product’s Labeling 

Each registrant wishing to use WDL submits an application for amended registration containing 

new labeling statements as described in more detail below. (See Section V.) If EPA approves the 

application, the registrant would be responsible for creating, publishing, and maintaining the 

website containing the WDL. This would be in addition to all other regulatory requirements 

related to pesticide registration and labeling. WDL would not change EPA’s policies about and 

requirements for submission and review of final printed labeling. Registrants could control the 

formatting of the rendered output of the labeling, so long as the rendered output conformed to the 

existing applicable requirements at 40 CFR Part 156 (e.g. 40 CFR 156.10(a)(2)). 

Users would follow the URL on the pesticide container label to the appropriate website. They 

would enter the unique identifier for the product and state, and then select the use site from an 

established list of some or all uses approved on the master labeling for inclusion as part of the 

WDL (known as a “pick list”; see http://www.epa.gov/pesticides/foodfeed/ for EPA’s 

recommended terminology for some commodities). The website would return a streamlined 

version of labeling that includes all general information from the labeling and only the use 

directions and restrictions related to the specific state and site of use. The user would verify that 

the date on the WDL rendered output was later than the container’s released for shipment date

(i.e., WDL labeling would be legally valid only if it bore an approval date on or after the released 
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for shipment date). The user could print the WDL, save it electronically, or view it. Printing the 

WDL would not constitute production by the user as defined at 40 CFR 167.3. See 75 FR 82011, 

82022; December 29, 2010. The user would be responsible for complying with either the WDL 

or the container labeling. Also, the user would be responsible for complying with applicable 

requirements (e.g., state regulations) that require users to maintain a copy of the labeling used for 

application. The use of WDL would not impose any additional recordkeeping requirements on 

users.

C. New Labeling Statements

In order for WDL to be enforceable, the pesticide product’s container label needs to reference the 

WDL. See FIFRA § 2(p)(2). The Agency is recommending a statement be added to the container 

label of each pesticide product using WDL and on the rendered output of the WDL. For WDL 

labeling to receive EPA approval, the statement should: (1) direct users to the relevant website, 

(2) note that the electronic version of the labeling is also legally valid, and (3) inform users in 

cases where the additional labeling conflicts with the container label, the user may choose which 

version of the labeling to follow. The statement should make clear that for areas of overlap or 

conflict, the user must use only one set of labeling instructions, either the attached container 

label or the downloaded labeling. This statement should appear at the beginning of the directions 

for use and might read as follows:

“You may obtain additional labeling from {insert website URL}. If using the 

additional labeling to make an application of the product, you must possess a copy 

of this additional labeling at the time of application. It is a violation of federal 

law to use this product in a manner inconsistent with its attached label or any 

additional labeling, including any web-distributed labeling. In instances where 

the additional web-distributed labeling conflicts with the container label, the user 

may choose a single, valid version of the labeling to follow. However, for areas 

of overlap or conflict, the user must use only one set of labeling instructions, 

either the attached container label or the web-distributed labeling.”

To facilitate linkage to labeling that changes over time, pesticide labeling for products using 

WDL should bear a released for shipment date and a unique identifier. These pieces of 

information would be used to match the product with the correct set of WDL. The released for 

shipment date and unique identifier, both clearly identified as such, must appear either on the 

pesticide container or on the labeling. The labeling should inform the user of the specific 

location on the container or labeling of the released for shipment date and unique identifier. This 

statement should follow the WDL statement listed above.

“The released for shipment date is in DDMMYYYY format and can be found {location, 

e.g., on the neck of the container}. The unique identifier format is {format, e.g., 10 character 

alpha-numeric combination} and it can be found {location, e.g., on the neck of the container}.”

The first page of the rendered output of WDL should include a statement indicating the legal 

validity of the label and explaining how labeling must be followed when different versions are 
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available to the user. For example, WDL could contain the following statement in a prominent 

location, for example, at the top of the page:

“This labeling is legally valid only for use in {state} and only with container of 

product {name of product & unique identifier} that bears a “released for 

shipment” date on or before {date of website access}. For pesticide applications 

following this labeling, you must possess a copy of this labeling at the time of 

application. If this labeling conflicts with labeling found on the pesticide product, 

use only one set of the labeling instructions in its entirety. Do not mix and match 

labeling directions.”

“Currently the user is responsible for complying with the requirements of product 

labeling obtained when the user took possession of the product’s container. The 

user must comply with all instructions and requirements in the labeling [FIFRA § 

12(a)(2)(G)] and must keep the labeling as long as the user has the container 

[FIFRA § 12(a)(2)(A)]. Similarly, the user who relies upon WDL may meet this 

requirement by maintaining a copy of the labeling or using some other form of 

recordkeeping in order to meet FIFRA’s requirements. In the situations described 

above where the WDL labeling conflicts with labeling on the pesticide container, 

the user must be able to identify which labeling was used and followed at the time 

of the pesticide’s application.”

Subsequent pages of the labeling should include an abbreviated legal statement that references 

the primary statement on legal validity of the labeling. For example:

“This labeling is legally valid only for use in {state} and only with the container 

of {name of product & unique identifier} that bears a “released for shipment date” 

on or before {date of website access}. See page 1 of this document for additional 

legal requirements on the use of this labeling.”

The registrant also should ensure that the web-distributed labeling, if printed, includes on each 

page the following statements:

“This web-distributed labeling was rendered by accessing {website} on {date}.” 

“{Product name} Web-Distributed Labeling – Page {page number} of {total pages}.”

In addition to the information and statements listed above, the registrant may include a Quick 

Response code or a similar symbol capable of being scanned by handheld devices to connect to 

the internet and to return the website listed on the container label or accompanying material. Per 

Section 2(p)(2) of FIFRA, the content the Quick Response code or other similar symbol

references would be considered labeling and therefore subject to review by the Agency.

D. Website 

1. WDL Content
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After the user searches by unique identifier, state, and site, the website should provide the user 

with the general labeling content that applies across all use sites as well as the content specific to 

the use site(s) requested by the user. The labeling content provided to users should be 

subdivided by use site and state. Additional subdivisions, such as application method, may be 

acceptable on a case-by-case basis. 

The WDL rendered output should also include the statements and content listed in Unit III.C. or 

equivalent. The rendered format of the labeling must conform to existing applicable standards at

40 CFR Part 156.

Where practicable, all WDL website functionality and rendered output should be accessible by 

handicapped individuals.

2. Website References on Labeling

Registrants (or their content providers) may develop a website for WDL distinct from existing 

websites. The simplest WDL URL would direct the user to a website where he or she could 

input the unique identifier, state, and site of application. The website would return only the 

WDL requested by the user. Any links from this WDL website to other information could 

clearly indicate through a disclaimer statement that the user is exiting the portion of the website 

considered labeling and going to a website that is not part of the product’s labeling.

 

Should the registrant wish to add or retain a reference to the company’s website on the labeling, 

including by directing the user to the registrant’s primary website to download labeling, the 

registrant should be aware that the website becomes labeling under FIFRA and is subject to 

review by the Agency. For example, if the container label directed the user to 

www.registrant.com to download the WDL, all content on www.registrant.com would be 

considered labeling. If the website is false or misleading, the product would be misbranded and 

unlawful to sell or distribute under FIFRA section 12(a)(1)(E). 40 CFR 156.10(a)(5) lists

examples of statements EPA may consider false or misleading.

In addition, regardless of whether a website is referenced on the product's labeling, claims made 

on the website may not substantially differ from those claims approved through the registration 

process. FIFRA section 12(a)(1)(B). Therefore should the Agency find or if it is brought to our 

attention that a website contains claims substantially differing from the EPA approved 

registration, the website could be referred to the EPA's Office of Enforcement and Compliance 

Assurance. 

3. Website Function

EPA will consider website functionality when deciding whether to approve an amendment to add 

WDL. In order to ensure that the WDL website, and thus pesticide labeling, is readily available 

to users, ideally, the website would have minimal down time and be accessible 24 hours a day, 

every day of the year, and be available 99.9% of the time. The website would also have a 

reasonable minimum response time. The content provider should consider the potential number 

of people that may attempt to access the site at one time. 
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Registrants (or their content providers) should not limit users from accessing labeling content 

through the website by requiring users to log in or pay a fee even where other non-WDL services 

do require users to log in or pay a fee. The website should not require advanced (i.e., more than 

current common computer capabilities or standard software) computer systems or software. The 

labeling content should be provided, at a minimum, in PDF format, although registrants may 

choose to make WDL available through other technology, such as tablets or smart phones. Users 

should not be required to download software specific to the WDL site, other than the Adobe 

Acrobat Reader available for free download. The website should direct users who do not have 

the Adobe Acrobat Reader program installed on their computers to the website where users can 

download and install the program.

The website URL should be easy to read and easily identifiable, generally with no more than 25 

characters. The URL should link directly to the WDL webpage where the user can search for the 

labeling content by unique identifier, state, and use site. When designing websites, registrants 

should be aware that many rural areas still lack broadband internet access. 

4. Website Security

Registrants should ensure secure access to upload or change labeling on the WDL website. 

Registrants would be responsible for ensuring that the content of the WDL site, including 

labeling, is accurate and up to date. Registrants should ensure the labeling provided from the 

WDL website (rendered output) cannot be altered by users. EPA recommends that registrants 

maintain an audit history for users performing any activity other than accessing labeling.

5. Website Usage Data

In order for the EPA to analyze the success, needs, and future direction of the WDL program, 

EPA may consider including a condition on the registration requiring the registrant to submit the 

website usage data to EPA. Note: EPA does not wish to receive information that identifies 

specific users of the website and such information should not be submitted. Website usage 

information could include:

• Number of website hits

• Average time user spends on the website

• Number of downloads/printed labels

• Other web content that is provided 

o Other content that is accessed by the users

EPA may require this information not only as totals, but also by product, by state, and by use 

site. If submitting confidential business information (CBI), clearly mark it confidential. CBI 

will be handled in accordance with 40 CFR Part 2 subpart B and where applicable 40 CFR 

158.33.

V. What Registrants and Applicants Can Do

A. Adoption of Web-Distributed Labeling 

To initiate the process of adding WDL to an existing product registration, the company would

file an application for an amendment with EPA. In addition to any other required elements of the 

application, applications that incorporate WDL should include the master labeling and examples 

(preferably at least two) of the labeling in the rendered output (state- and site-specific labeling). 
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Adding WDL to an existing product registration is not necessarily an action covered by the 

Pesticide Registration Improvement Act (PRIA). Submitting an amendment that only seeks to 

add WDL to labeling would be a non-PRIA Fast Track action. However, a registrant could 

include an application to amend labeling to include WDL as part of an action covered by PRIA, 

such as adding a new use site. 

To add WDL to a new product’s labeling, the registrant would include the master labeling and 

examples (preferably at least two) of the labeling in the rendered output (state and site-specific 

labeling) with the package seeking to register a new product. 

Registrants could submit WDL to EPA as electronic files, such as a link to the appropriate 

website or a PDF file. EPA would also accept printed copies of the WDL for review.

As part of the approval process, EPA may review the website, URL, and the rendering of 

labeling content through a link to a draft of the website not available to the public. EPA may

ensure the URL is easy to read and that it directs the user directly to the WDL webpage. EPA 

may also review the website on a case-by-case basis to evaluate ease of use. EPA would also 

review the labeling in the rendered output to determine, on a case-by-case basis, if it correctly 

reflects the approved master labeling. Note: Only the master labeling would be stamped 

"accepted"; the sample rendered WDL labeling would not be stamped. As a condition of 

approval of the amendment, EPA may require the registrant to amend the website to provide 

updated labeling within a specific timeframe after the revised labeling receives all necessary 

approvals from EPA and a state. EPA anticipates that it would require registrants to provide 

updated labeling within a specific time frame if necessary to implement risk mitigation measures. 

For other changes, such as adding a new use, EPA would likely leave the labeling amendment 

schedule to the discretion of the registrant, provided the labeling and website are updated within 

18 months of approval by EPA as is the standard timeframe for updating labeling when new 

labeling is approved. See 40 CFR 152.130(c).

Upon EPA approval of the labeling, EPA recommends that registrants provide at least 2 versions 

of the final WDL in the rendered output (state- and site-specific labeling) to EPA, in addition to 

the final printed labeling as required by 40 CFR 156.10(a)(6).

B. Supplemental Distributors

The label of a distributor product must be the same as the label of the parent product, except as 

provided in 40 CFR 152.132(d). If the primary registrant for the product uses WDL, the 

supplemental distributor of that product can choose whether to participate in WDL for the 

supplementally distributed product under the terms of the agreement between the primary 

registrant and supplemental distributor. However, if the primary registrant does not use WDL

for a product, the supplemental distributor of that product may not use WDL for that product.

VI. Effective Dates

This Notice represents a proposal. EPA will not begin accepting applications to use WDL for 

products until the Agency publishes a final Notice.

VII. Addresses to Use
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Registrants should send notifications and amendments to one of the following addresses: 

U.S. Postal Service Deliveries

The following official mailing address should be used for all correspondence or data submissions 

sent to OPP by U.S. mail:

Document Processing Desk (AMEND) (Distribution Code as identified in PR Notice 2006-1)

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Ariel Rios Building1200 Pennsylvania Ave., NW

Washington, D.C. 20460-0001

Personal/Courier Service Deliveries

The following address should be used for all correspondence or data submissions that are handcarried or sent by courier service Monday through Friday, from 8:00 AM to 4:30 PM, excluding 

Federal holidays:

Document Processing Desk (Distribution Code as identified in PR Notice 2011-X) (AMEND) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

VIII. For Further Information 

If you wish to obtain further information on this notice, please contact Michelle Arling, 

arling.michelle@epa.gov, 703-308-5891. For questions about a specific product or active 

ingredient, please contact the product manager.

IX. Specific Areas for Comment

A. Would an appendix with sample master labeling and web-distributed labeling rendered 

output assist in understanding the PR Notice and how to follow the recommendations in the PR 

Notice?

B. The PR Notice suggests that it “is targeted towards pesticide products marketed primarily to 

applicators for use in the course of commercial activity.” Please comment on the scope of 

coverage. Should the Agency expand or contract the targeted products? Are there alternate 

ways to describe the targeted products?

C. Should the Agency consider combining the released for shipment date and the unique 

identifier into a single alpha-numeric combination? If so, why? Please provide suggested 

definitions for any proposed alternative.

D. Should the released for shipment date and unique identifier have a standard location on the 

container or pesticide labeling? If so, where? If not, why?
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E. Should EPA approve web-distributed labeling for one or some, but not all, uses listed on a 

product’s labeling? If so, how would users know that no web-distributed labeling was available 

for their intended use?

F. Should EPA consider only accepting WDL submissions to the Agency for review as electronic 

files?

G. Please provide comments on the web-distributed labeling statements and their recommended 

location. Should they be located at the beginning of the directions for use? Should they be a 

separate section on the labeling, similar to the Agricultural Use Box that conveys information 

about the Worker Protection Standard? Would either approach make the user more likely to read 

and comply with the information?

H. Please provide comments on the minimum functionality discussed in Unit IV. D. Are the 

proposed standards reasonable? If not, please suggest alternative guidelines.

I. Please provide any other comments on the PR Notice. If you disagree with or do not 

understand any aspect of the PR Notice, please describe the area and an alternative that 

incorporates your suggestions.

___________________________ Dated:_________________

Steven Bradbury, Ph.D., Director

Office of Pesticide Programs

U.S. Environmental Protection Agency